Every motor carrier has to keep a driver qualification (DQ) file for every driver who operates a commercial motor vehicle, including the owner if the owner drives. It's one of the first things an auditor asks for, and incomplete DQ files are one of the most common violations found in audits.
The requirement is in 49 CFR 391.51. Here's what has to be in the file.
Documents collected at hire
- Employment application (391.21). Signed by the driver, listing every employer for the past 3 years, plus any commercial driving jobs going back 10 years for CDL drivers.
- Motor vehicle record (MVR) from every state (391.23). Covers the past 3 years, from every state where the driver held a license. Must be requested within 30 days of the driver's start date.
- Safety performance history from previous DOT employers (391.23). Inquiries to every DOT-regulated employer from the past 3 years, plus the driver's responses or your record of a good-faith effort.
- Road test certificate (391.31) or an equivalent (391.33). A valid CDL can stand in for the road test for most drivers.
- Medical examiner's certificate (391.43). See the 2025 change below.
- Clearinghouse pre-employment full query (382.701). Required before a CDL driver performs any safety-sensitive work.
Documents added every year
- Annual MVR (391.25). Pull a new MVR from each state where the driver holds a license at least once every 12 months.
- Annual review of driving record (391.25). A note, signed by the person who reviewed it, stating whether the driver still meets the minimum requirements.
- Annual Clearinghouse limited query (382.701). At least once a year for every CDL driver you employ.
The 2025 medical certification change
As of June 23, 2025, medical examiners send CDL and CLP drivers' medical certification results electronically to FMCSA, which forwards them to the state licensing agency. For those drivers, the medical certification now shows on the driver's MVR. Carriers keep the MVR as proof instead of relying on a paper medical card.
For non-CDL drivers of commercial vehicles, you still keep a copy of the medical examiner's certificate in the file, plus a note that you verified the examiner is listed on the National Registry.
What doesn't go in the DQ file
Drug and alcohol test results don't go in the DQ file. 49 CFR 382.401 requires them to be kept in a separate, secure file with limited access.
How long to keep it
Keep the DQ file for as long as the driver works for you, plus 3 years after they leave (391.51(c)). Annual MVRs, annual reviews and medical certificates can be removed 3 years after they're created (391.51(d)).
The most common DQ file mistakes
- No file at all for the owner who also drives
- MVRs missing for a state where the driver previously held a license
- Previous employer inquiries never sent, or sent with no record kept
- An expired medical certification nobody caught
- Annual review missing, or not signed
Keep it audit-ready
A DQ file is only as good as the last time someone checked it. Expiration dates are where most carriers slip.